Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1910.120; 1910.121|
November 29, 1990
Roy Waters, Captain
Columbus Fire Department
205 10th Street
Columbus, Georgia 31993
Dear Captain Waters:
This is in response to your inquiry concerning the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120) and the proposed Accreditation of Training Programs for Hazardous Waste Operations standard (29 CFR 1910.121). Please accept my apology for the delay in this reply.
You have requested OSHA to review your program for accreditation. In addition, you have asked whether Hazardous Material Response Teams need an asbestos training course and if so, which one(s).
As you know, 29 CFR 1910.121 is a proposed regulation which at this time does not include accreditation for emergency response training under 29 CFR 1910.120(q). Consequently, OSHA is not reviewing programs for accreditation at the present time. In order to ensure fairness to all applicants for accreditation, we have adopted a policy not to review or hold any training programs until after the final rule is published. In the interim, you may be interested in participating in informal hearings on the proposal. I am enclosing information on the hearing dates and locations.
Under the training requirements for emergency responders (29 CFR 1910.120(q)), we do not mention specific courses that must be taken since the training needs to be based on the duties and functions to be performed for each responder of an emergency response organization. If responders may be exposed to asbestos, then this hazardous substance must be included in the training program. In addition, if the responders may be involved in removal of the asbestos, then the training requirements under 29 CFR 1926.58 (Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite) may also apply.
Employees of your fire department are exempt from Federal OSHA standards because they are public employees. However, with respect to 29 CFR 1910.120, state and local government employees are covered by regulations identical to our final rule that have been issued by the US Environmental Protection Agency (EPA).
You can contact them directly at the following address and telephone number:
Vickie SantoroI hope this information is helpful.
U.S. EPA Environmental Response Team
Edison, New Jersey 08837
Telephone: (201) 321-6740
Patricia K. Clark Director
Directorate of Compliance Programs
July 23, 1990
Occupational Safety & Health Administration
200 Constitution Avenue, N.W.
Francis Perkins Building
R N 3603
Washington, D.C. 20210
RE: Accreditation of Training Program
Pursuant to the attached letter from the U.S Department of Labor, Occupational Safety and Health Administration, dated April 9, 1990 I am respectfully requesting clarification on the attached letter and 29 CFR 1910. Accreditation of Training Programs for Hazardous Waste Operations; Notice of Proposed Rulemaking.
1. After a cursory review of our training program on March 23, 1990 it appears that all elements of 29 CFR 1910.120 were met.I am requesting that O.S.H.A. consider reviewing our program for accreditation. Although not required, we have worked very diligently to initiate a training program that exceeds the requirements of the Standard with special emphasis on employee safety and health.
2. Please clarify the above standard to interpret whether or not our Hazardous Material Response Team will need an Asbestos Training Course and if so, which one(s). The Environmental Protection Agency is offer in Asbestos Demolition and Renovation Inspection Techniques Workshop August 6, 7, 8, 1990 in Atlanta, Georgia. If an Asbestos Course is required will the above course suffice?
3. I feel that our department has met all of the training requirements in 29 CFR 1910.120. However according to the Proposed Rulemaking the Standard is not proposed to accredit training programs in emergency response.
Our current training program requires the following:
Operational Level: 32 Hours Technician Level: 72 Hours Specialist Level: 104 HoursPlease consider this request for a more specific review of our program and accreditation. It is of paramount importance that we have our training program accreditated. This has been our ultimate goal for two years.
Please advise me as soon as possible concerning this most worth while request.
Your cooperation and continued support will be greatly appreciated.
Robert E. Ledford Chief
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